Legal Opinion
Harold Chakales Linda Carol Chakales v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided March 27, 1996No. 95-1742PublishedCited by 56 opinions
1Opinion of the Court
SCHWARZER, District Judge.
Taxpayers Harold and Linda Carol Cha-kales (“Chakales”) appeal from a decision of the United States Tax Court upholding the assessment of penalty interest by the Commissioner of Internal Revenue. Harold Chakales and Linda Carol Chakales v. Commissioner, 68 T.C.M. (CCH) 479, 1994 WL 454539 (1994). We have jurisdiction under 26 U.S.C. § 7482(a) and affirm.
BACKGROUND
Chakales was among several thousand taxpayers who participated in a program operated by First Western Government Securities (“First Western”) involving straddle transactions of forward contracts to buy and…
2Cases cited14 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Freytag v. CommissionerSupreme Court of the United States · 1991
- United States v. BoyleSupreme Court of the United States · 1985
- Freytag v. CommissionerUnited States Tax Court · 1987
- Rybak v. CommissionerUnited States Tax Court · 1988
9 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- Duffie v. United StatesCourt of Appeals for the Fifth Circuit · 2010
- Reko v. Creative Promotions, Inc.District Court, D. Minnesota · 1999
- James B. Thomas, Plaintiff-Appellee/cross-Appellant v. United States of America, Defendant-Appellant/cross-AppelleeCourt of Appeals for the Sixth Circuit · 1999
- Zachary H. Sacks and Salley Sacks v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1996
- American Federation of State, County & Municipal Employees v. City of BentonCourt of Appeals for the Eighth Circuit · 2008
51 more not listed; retrieve them via the Exa API.